Wise Group plc

We have adopted the Wise Code of Conduct which is filed as Exhibit 11.1 to this Annual Report, which applies to all of our officers, directors and employees including contingent workers and sets forth our Company’s values and minimum global standards of behavior, as well as principles and procedures related to, among other things: compliance with all applicable laws, rules, and regulations; information security; conflicts of interest; and anti-corruption. Our Code of Conduct is a “code of ethics,” as defined in Item 406(b) of Regulation S-K. We will make any legally required disclosures regarding amendments to, or waivers of, provisions of our Code of Conduct on our website. The information contained on, or accessible from, our website is not part of this Annual Report by reference or otherwise.